the Texas Land and Title Association, the Texas Mortgage Brokers Association, the
Texas Credit Union League and the Texas Bankers Association in a comment letter
opposing changes to the make up of the Annual Percentage Rate (APR). As
proposed, those changes would be detrimental to both community banks and the
consumers those banks serve. Additionally, the inclusion of non-lender costs
may very well result in a contraction of firms providing mortgage-related
services, especially in rural areas. To read the joint comment letter, click here.